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HMRC internal manual

Tax Compliance Risk Management

Managing our relationship with large business customers: working with Low Risk customers: a relationship of trust

A Low Risk customer is one who HMRC trusts to:

  • be open and transparent with HMRC in real time;
  • have systems and processes in place to produce figures for their tax returns which are accurate in all material respects; and
  • not get involved in tax planning which does not support genuine commercial activity.

The designation of Low Risk status defines HMRC’s approach to a particular customer. We trust that our Low Risk customers will be open and transparent, bring issues to us in real time and, in all material respects, pay the right tax at the right time. Within this relationship HMRC will, in general, not initiate interventions apart from certain interventions which potentially apply to all customers, such as mandatory work or projects and campaigns.

In cases where a Low Risk customer breaches this trust HMRC will take appropriate action which may include removal of Low Risk status. See TCRM2470.